Banking Regulation 2025

GREECE Law and Practice Contributed by: Paris Tzoumas, Vivian Efthymiou and Dimitrios Mekakas, Zepos & Yannopoulos

euros at no extra cost and enable the speedy transfer of money at any time (24/7). AML/CFT rules On 19 June 2024, the EU introduced new leg - islation to strengthen its AML/CFT framework through an ambitious legislative package com - prising Regulation (EU) 2024/1620 (“AMLA Reg - ulation”), Regulation (EU) 2024/1624 (“AML Reg - ulation”) and Directive (EU) 2024/1640 (“6th AML Directive”), with the aim to harmonise AML/CFT rules across EU member states, enhance super - vision and enforcement, and increase transpar - ency in financial transactions. In summary, a new EU authority dedicated to AML/CFT (AMLA) was established, anti-money laundering rules were for the first time thoroughly harmonised through - out the EU, new obliged entities and stricter due diligence measures were introduced, and clearer rules were set on how financial intelligence units (FIUs) and supervisors work together. The major - ity of the new AML measures will apply as of 10 July 2027. Consumer credit In October 2023, Directive (EU) 2023/2225 (Consumer Credit Directive 2) was published to reform the existing consumer credit regime which applies to credit institutions and other financial institutions providing consumer loans. EU member states must transpose Consumer Credit Directive 2 into their national law by 20 November 2025, with the new measures taking effect from 20 November 2026. Creditors (and especially Buy-Now-Pay-Later (BNPL) provid - ers), as well as credit intermediaries that did not previously fall within the scope of the consumer credit regime under Directive (EU) 2008/48, will have to re-assess their model, since Consumer Credit Directive 2 provides for a broader scope

of application and types of credit previously exempted (such as BNPL) will be brought into the scope of the new regime. National Laws At national level, the most significant changes that took place in 2024 were as follows. • Greek Law 5123/2024 (“Law 5123”) was recently passed by the Greek parliament and will reform and harmonise the legal frame - work for the establishment and enforcement of pledge rights, amending the current frame - work. A material change is the establishment of the Single Electronic Register of Pledges, which will centralise the registration of pledge agreements. In terms of application, Law 5123 will come into force either following the publication of the Hellenic Cadastre’s deci - sion over the commencement of the opera - tion of the above register or on 31 December 2024 (whichever occurs earlier). However, the long stop of 31 December 2024 may be further extended by virtue of a ministerial decision. • Law 5113/2024, also known as the DLT Securities Law, has supplemented Regula - tion 2022/858 (the DLT Pilot Regulation). It amends, among other things, the definition of financial instruments in Law 4514/2018 (transposing MiFID II in Greece) to include instruments issued by the use of Distributed Ledger Technology (DLT), and clarifies that all laws and regulations applicable to trans - ferable securities will equally apply to DLT transferable securities. This law aligns Greek corporate and securities regulations with the evolving digital landscape, emphasising tech - nological neutrality while boosting operational efficiency.

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